MedPAC Holds March 2018 Public Meetings

Background

On Thursday, March 1, 2018, the Medicare Payment Advisory Commission (MedPAC) met as scheduled for their March public meeting in Washington, DC. The purpose of this and other public meetings of MedPAC is for the commissioners to review the issues and challenges facing the Medicare program and then make policy recommendations to Congress.

What You Need To Know

Unified Payment System for Post-Acute Care (U-PAC)

The IMPACT Act of 2014 requires the commission to develop a unified, site-neutral prospective payment system (PPS) spanning the four PAC settings (SNF, IRF, LTACH, and HH) that bases payment on patient characteristics rather than the site of service. During the March MedPAC meeting, the following was discussed:

  • MedPAC believes a U-PAC could begin to be implemented in 2021; blending of current payment rates across PAC settings to correct for biases could begin as early as 2019, prior to the implementation of the U-PAC
  • MedPAC acknowledged further analysis was needed pertaining to sequential stay payments
    • Sequential stays are back-to-back stays in a PAC setting, such as a home health episode that follows a SNF stay or multiple home health episodes occurring consecutively
    • The later stay in a sequence is typically less costly and MedPAC believes payments for these stays should be adjusted accordingly
  • MedPAC discussed the possibility of a bundled payment option under the U-PAC, and there was consensus that further analysis of this model is needed
    • A bundled payment would entail a third-party entity, such as a convener, who would manage and adjudicate payment to providers for episodes of care across the PAC settings

Encouraging Medicare Beneficiaries to Use Higher-Quality Post-Acute Care Providers

At Medicare Beneficiaries to Use Higher-Quality Post-Acute Care Providers a previous MedPAC meeting the Commission reviewed hospital discharge planning, and the factors that influence beneficiary decision making when selecting a PAC provider. Commissioners concluded that permitting hospitals to assist beneficiaries with identifying higher-quality PAC providers could be beneficial for both patients and the Medicare program. During the March meeting, MedPAC discussed:

  • A potential framework for maintaining beneficiary freedom of choice while providing more useful information on the quality of PAC providers
  • MedPAC commissioners were split on whether or not the framework for identifying higher-quality PAC providers should be prescriptive or flexible
    • Prescriptive: CMS would set quality measures which identify higher-quality PAC providers
    • Flexible: discharging hospitals would set quality measures which identify higher-quality PAC providers

PTS will continue to monitor for updates and keep our valued partners informed.

If you have any questions, please contact Matt Nash, Vice President of Strategic Development: mnash@preftherapy.com

CMS discusses timeline for RCS-I Implementation on ODF

The Centers for Medicare and Medicaid Services (CMS) stated there is no timeline for the implementation of the proposed Resident Classification System-I (RCS-I) on their Open Door Forum (ODF) held on March 8th, 2018.

Background

The Advanced Notice of Proposed Rulemaking (ANPRM) released by CMS in May 2017 introduced

RCS-I as a potential replacement to the RUG based prospective payment system. Since the release, there has been much debate and speculation as to when this new payment system would take effect. CMS had not provided any detail regarding the timeline for its implementation until this most recent ODF.

Summary of ODF

On the March 8th, 2018 ODF, CMS discussed the following pertaining to RCS-I:

• The ANPRM did not finalize any policies regarding RCS-I and therefore there is no specific timeline for its implementation

• CMS acknowledged that time will be needed for software development as well as other stakeholder requirements in order to implement RCS-I

• CMS stated they are unsure if they will be publicly responding to all of the comments and feedback provided by stakeholders after the release of the ANPRM

• CMS acknowledged receiving feedback with regards to how RCS-I could be implemented/integrated with the Unified Payment System for Post-Acute Care (U-PAC) and that they are including this in their analysis

 PTS Take

After the release of the ANPRM last May, PTS along with the majority of PAC providers expected an October 2018 implementation of RCS-I. Over the past month or so, we have heard rumors that the implementation of RCS-I would be delayed. Based on the recent CMS ODF, we believe RCS-I will most likely not be implemented this October, and may very well be integrated into the U-PAC implementation, which would not take effect until 2021.

PTS continues to prepare for a potential October 2018 implementation of RCS-I as it remains a possibility until CMS releases the Proposed Rule for FY 2019 in late April. We believe that this change in payment system will occur, if not this year, certainly in the near future. The Proposed Rule expected in April would also outline any changes to the current ANPRM outline of RCS-1.

PTS will continue to monitor for updates and keep our valued partners informed.

If you have any questions, please contact Matt Nash, Vice President of Strategic Development: mnash@preftherapy.com